Privacy Policy
1. Introduction
Schonfeld Strategic Advisors LLC, and its affiliates (together the “Firm”, “we”, “our” or “us”) aim to protect your privacy as far as possible. This Online Privacy Notice describes the types of information we may collect from you when you visit www.schonfeld.com and other Firm-owned websites (collectively, the “Website”) or otherwise interact with us online. The Online Privacy Notice further explains how we may use and disclose your information, as well as your ability to control certain uses of your personal information. This Online Privacy Notice is in addition to any separate annual privacy disclosures that we may send you under applicable privacy law.
For the purposes of the relevant “Data Protection Legislation” (as defined below), the data controller is the Firm. Our contact details are set out at the end of this notice.
2. How we obtain your information
We may collect personal information from you when you use our Website, when you (or any entity you represent) enter into a contractual relationship with us, including, for example, as a service provider or investor, or otherwise engage in communication with us. Accordingly, we collect information about you from a variety of sources, which may include:
- any documents submitted to us, including any application forms;
- our communication or correspondence with you, such as when you contact us by letter, telephone, email or any other means of electronic or personal communication;
- your use of our Website (including by use of cookies; for our cookie policy, please visit the Terms of Use)
- your use of the Guest Wi-Fi services on your personal device(s) at our offices; or
- third parties, in connection with potential employment or other prospective contractual engagements.
Please note that, in accordance with regulatory requirements, we may record calls made on certain employees’ landline and mobile telephone lines.
3. What information do we collect?
Depending on the nature of your relationship with the Firm, we may collect or may have collected the following categories of data about you in various ways, such as through our Website:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
- Other personal information such as your age, date of birth and marital status;
- Characteristics of protected classifications under California or federal law;
- Professional or employment-related information;
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes; and
- Other information you or others may provide to us during your communications or relationship with us, for our operational or business purposes.
In compliance with relevant law, we may retain information as needed or appropriate to serve our legitimate business purposes or as required by law.
You are not obliged to provide us with your information where it is requested but this may affect our ability to continue our dealings with you. If you provide personal data on behalf of another person, it is your responsibility to notify that individual that you have provided their information to us and direct them to this notice.
Our Services are not directed toward or intended for children under the age of 18. If you are under the age of 18, you should not provide any personal information to us without your parent or guardian’s express and verifiable written consent. We do not knowingly collect any information from persons under the age of 18 years of age. By using or accessing this site you confirm that you are at least 18 years of age.
4. Our use of your information
We may store and process your information including, but not limited to, in the following ways and for the following purposes:
- Provide our products and services;
- Communicate with you (and, where required by applicable law, we will obtain your explicit consent to do so);
- Establish and manage our business relationships;
- Personalize your experience with us, including on our Website;
- Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Website, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; and performing other internal functions);
- Maintain and enhance the safety and security of our Website, products and services, and prevent misuse;
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- Comply with and enforce applicable legal requirements, relevant industry standards and policies.
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
5. How we share your information
We may share your information internally within the Firm, with our third-party business partners, business associates, subcontractors and other third parties for the purposes set out below.
- Within the Firm and to our third-party service providers: We may disclose your personal information to third parties, including, but not limited to, our affiliates, subcontractors, agents and any person who provides professional, legal, tax or accounting advice or other services to the Firm. All such third parties are required to maintain the confidentiality of the Firm who have a need for such information to the extent they receive it.
- Potential buyers, transferees, merger partners or sellers: We may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers in connection with any actual or potential transfer or merger, sale, acquisition, assignment, transfer, or other disposition of part or all of the Firm’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
- Legal reasons: We may also disclose your personal information or any portions thereof (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement; and (b) respond to requests from any regulatory, supervisory or governmental authorities.
6. How we transfer your information
The Firm operates a global business and our use of cloud-based technologies and operation in a global marketplace means that your information may be shared by us outside your country and such jurisdictions may not offer the same level of data protection as in your home jurisdiction.
Where we transfer your information outside of the UK or EEA, we will ensure that personal data is protected and transferred in accordance with applicable legal requirements, which can be done as follows:
- the country to which we send personal data may be deemed to provide adequate protection as approved by the European Commission or UK Information Commissioner’s Office (the “ICO”);
- the recipient may have signed a contract based on standard contractual clauses approved by the European Commission (“model clauses”), obliging them to protect your personal information; or
- if the recipient is located in the US, it may be a certified member of the Data Privacy Framework.
7. Security and retention of information
We take the protection of your personal information seriously, and have security measures, controls and policies in place.
We will hold your personal information on our systems for the longest of the following periods:
- as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;
- the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
- any retention period that is required by law; or
- the end of the period in which litigation or investigations might arise in respect of your use of our Website or the services that we provide to you.
8. Cookies
For further information on our use of cookies, please refer to the Terms of Use.
9. Your rights
Data protection laws, including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016) (“GDPR”), the UK Data Protection Act 2018 and the California Consumer Privacy Act of 2018 (“CCPA”) (collectively, the “Data Protection Legislation”) may provide you with rights to access data, as well as rights for data to be erased, corrected, used for only limited purposes, not used at all, or transferred to you or a third party.
In n certain circumstances individuals in the European Union and UK have the following rights
- Right of subject access: The right to make a written request for details of personal data about you held by the Firm and a copy of that personal data.
- Right to rectification: The right to have inaccurate information about you rectified.
- Right to erasure (‘right to be forgotten’): The right to have certain personal data about you erased.
- Right to restriction of processing: The right to request that your personal data is only used for restricted purposes.
- Right to object: The right to object to the use of personal data.
- Right to data portability: The right to ask for personal data you have made available to us to be transferred to you or a third party in machine-readable formats.
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal data. If you withdraw your consent, this will not affect the lawfulness of the Firm’s use of your personal data prior to the withdrawal of your consent.
Under the CCPA, individuals who are residents of California have the following rights:
- Right to know what personal information the Firm has collected about the consumer, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer.
- Right to request Firm to delete personal information, subject to certain exceptions.
- Right to correct inaccurate personal information that the Firm maintains about a consumer.
- Right to opt out of the sale or sharing of your personal information.
- Right to limit the use or disclosure of sensitive personal information.
- Right to not receive discriminatory treatment for exercising your privacy rights.
These rights are not absolute: they do not always apply, and exemptions may be applicable. We may, in response to a request ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
To exercise any of these rights, on your behalf or as an authorized agent on behalf of someone else, or if you have any other questions about our use of your information, please email us at: [email protected]
10. Contact Us
If you have any questions about this privacy notice, or our privacy related practices, you can contact: [email protected]
11. Changes to Privacy Notice
This Online Privacy Notice may be amended from time to time without notice, in which case the date of this Privacy Notice will be revised.
If our Online Privacy Notice changes in any way, we will upload the latest version on our Website here.
If you have any concerns about our use of your information and are based within the EEA, you also have the right to make a complaint to a national data protection authority. For a current list of EEA authorities and the relevant contact details, please visit https://ec.europa.eu.
If you have any concerns about our use of your information and are based within the UK, you also have the right to make a complaint to the Information Commissioner. For further instructions, please visit https://ico.org.uk
If you have any concerns about our use of your information and are based in California, you also have the right to make a complaint to the State of California Department of Justice. For further instructions, please visit https://oag.ca.gov.
If you have any questions, comments or complaints about our privacy policy, please contact the Firm at [email protected], as your privacy and the confidentiality of your information are very important to us.